Booke v. County of Fresno et al

Filing 63

STIPULATION and ORDER to Continue the Motion for Summary Judgment deadlines. The Motion Hearing currently set for 1/12/2015 has been moved to 2/2/2015 at 01:30 PM in Courtroom 2 (AWI) before District Judge Anthony W. Ishii, signed by Magistrate Judge Stanley A. Boone on 12/17/2014. (Kusamura, W)

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Attorneys for Defendants
CITY OF SANGER, SANGER CHIEF OF POLICE
SILVER RODRIGUEZ, OFFICER ROBERT
PULKOWNIK, OFFICER ANGELA YAMBUPAH,
OFFICER JASON BOUST, and OFFICER PRESTON
LITTLE

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180 Montgomery Street, Suite 1200
San Francisco, California 94104

ALLEN. GLAESSNER, HAZELWOOD & WERTH, LLP

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DALE L. ALLEN, JR., State Bar No. 145279
[e-mail]
KEVIN P. ALLEN, State Bar No. 252290
[e-mail]
ALLEN, GLAESSNER, HAZELWOOD & WERTH, LLP
180 Montgomery Street, Suite 1200
San Francisco, CA 94104
Telephone:
[phone]
Facsimile:
[phone]

UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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ESPERANZA BOOKE, individually and
as personal representative of the Estate of
CHARLES SALINAS,

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STIPULATION TO CONTINUE MOTION
FOR SUMMARY JUDGMENT DEADLINES

Plaintiff,

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Case No.: 1:13-cv-00586-AWI-SAB

v.
COUNTY OF FRESNO, et al.,
Defendants.

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The parties seek an order of the court extending the deadline for plaintiff to file opposition

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to defendants’ motion for summary judgment, and the corresponding reply by defendants, due to

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a medical emergency delaying the deposition of an expert of the defendants. Dr. Matthew

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Sharps, disclosed as a cognitive expert for defendants, was set to be deposed on Monday,

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December 15, 2014. On Saturday, December 13, 2014, his wife suffered a heart attack and has

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been hospitalized. Dr. Sharps is not available as a result, and that may prejudice the ability of

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plaintiff’s effort to oppose the motion for summary judgment and/or adjudication filed by

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defendants. The current schedule calls for plaintiff’s opposition to be filed by December 29, 2014

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and the reply by January 5, 2015. The parties stipulate and request that the new date for
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opposition be January 19, 2015 and the new date of the reply be January 26, 2015. The parties

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further stipulate and request a continuance of the hearing date, which is currently set for January

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12, 2015, to a date on or after February 2, 2015.

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Dated: December 16, 2014

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ALLEN, GLAESSNER,
HAZELWOOD & WERTH, LLP
By:

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180 Montgomery Street, Suite 1200
San Francisco, California 94104

ALLEN. GLAESSNER, HAZELWOOD & WERTH, LLP

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/s/ Dale L. Allen, Jr.
DALE L. ALLEN, JR.
KEVIN P. ALLEN
Attorneys for Defendants
CITY OF SANGER, SANGER CHIEF OF
POLICE SILVER RODRIGUEZ, OFFICER
ROBERT PULKOWNIK, OFFICER
ANGELA YAMBUPAH, OFFICER JASON
BOUST, and OFFICER PRESTON LITTLE

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Dated: December 16, 2014

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LAW OFFICE OF ROBERT HAMPARYAN
By:

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/s/Laura M. Sasaki
LAURA M. SASAKI
Attorneys for Plaintiff
ESPERANZA BOOKE, individually and as
personal representative of the Estate of
CHARLES SALINAS

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IT IS SO ORDERED:

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Plaintiff’s opposition to defendants’ motion for summary judgment is due on January 19,

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2015 and defendants’ reply is due on January 26, 2015. The hearing on defendants’ motion for

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summary judgment is continued to February 2, 2015 at 1:30 p.m. before Judge Anthony W. Ishii.

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IT IS SO ORDERED.
Dated:

December 17, 2014
UNITED STATES MAGISTRATE JUDGE

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